The Anti Money Laundering Network (AML Network) wishes to formally inform Pan Gongsheng, People’s Bank of China, that previous email communications regarding critical procedural concerns in the Financial Action Task Force’s (FATF) February 2024 decision to remove the United Arab Emirates from its Enhanced Monitoring (“Grey List”) were not successfully delivered.
Establishing a Formal Record
AML Network hereby establishes a formal record of concern regarding the UAE’s delisting, which may have been granted despite unresolved systemic effectiveness issues. The decision has the potential to create supervisory risk for domestic and global correspondent banking systems by signaling compliance without verified enforcement outcomes.
Supervisory Concerns
The key question raised is on what evidentiary basis the UAE was rated as having “Substantial Effectiveness,” particularly when international sanctions activity involving UAE-based networks reportedly escalated post-delisting. AML Network emphasizes that international certification should be grounded in field-verified enforcement outcomes rather than procedural completion alone, as any divergence undermines the credibility of the evaluation framework.
Due Diligence and Domestic Risk Exposure
Premature removal from enhanced monitoring may lead domestic financial institutions to lower due diligence safeguards, inadvertently increasing exposure to illicit capital flows. AML Network stresses that, given China’s obligations under global finance frameworks, supervisory vigilance is essential in interpreting high-impact FATF determinations.
Two-Limb Test and Methodological Breach
AML Network highlights that FATF methodology requires both Technical Compliance and demonstrable operational effectiveness — the “Two-Limb Test.” Questions remain whether the UAE satisfied the effectiveness threshold at delisting, raising concerns about the integrity of FATF’s assessment process.
Formal Requests
AML Network requests that People’s Bank of China take the following actions:
- Governance Audit: Initiate an independent investigation into the 2024 UAE assessment process to restore methodological credibility.
- Technical Risk Reassessment: Conduct a formal review of UAE’s status incorporating post-delisting illicit finance and sanctions data.
Additionally, AML Network requires formal acknowledgment of this notice within 48 hours, along with a substantive written response addressing the supervisory, due diligence, and methodological questions outlined above.
The full investigative report is publicly available here:
Contact for Response:
Email: [email protected]